Examination of Witnesses (Questions 270-327)
MR MIKE
O'BRIEN QC MP, MR
DAVID CAPPER,
MS JILL
DUGGAN AND
MR CHRIS
DODWELL
2 JUNE 2009
Q270 Chairman: Good morning. Thank
you very much for coming in. You will be aware that we had a very
helpful session with Jill Duggan a few weeks ago, and we are very
glad to see her with you again this morning. Do you have an opening
statement?
Mr O'Brien: No, but perhaps I
could introduce my colleagues: David Capper, Head of the ETS team;
Jill Duggan, who, as you know, is the Head of International Emissions
Trading; and Chris Dodwell, Head of Policy, International Climate
Change, in the Department, who will be dealing with particularly
with some of the issues around Copenhagen.
Q271 Chairman: Thank you very much.
Would you like to start by telling us what your aims are in terms
of the emissions trading strategy?
Mr O'Brien: The key aim of emissions
trading is to enable us to get emissions reductions by setting
a cap and to get those emissions reductions at the least cost.
That is the primary aim. There are some other subsidiary aims
but I think they should be seen in that context. For example,
a carbon price will help assist certain technologies and make
them much more viable. I have put it in that way, but the objective
over the coming decade is to establish a strong emissions trading
system so that we can enable the cap to be effective not just
over the next decade but over the longer term, up to 2050, and
no doubt beyond in due course. We also have the objective of trying
to encourage the development of ETS systems in other parts of
the world. We know the Obama administration, for example, is very
interested in developing it. We know the Waxman-Markey Bill is
just completing its process through the House of Representatives
and will shortly go into the Senate. That makes a certain amount
of progress and includes a cap and trade mechanism. We would then
need to link up the various ETS systems so that we can create
a global market. We also need to see if we can bring the developing
countries into it. We are in the business, therefore, of developing
a global mechanism in due courseand I think it is still
some way away in terms of being globalwhich will enable
us to have an effective means of contributing, substantially to
the reduction of emissions.
Q272 Chairman: There are a number
of issues there which we will pursue in the course of the morning.
To start with the issue of the carbon price, when we did a previous
inquiry into Emissions Trading a couple of years ago, we felt
that there was some tension between the aim of achieving a carbon
price which would incentivise faster investment in the low-carbon
economy and a desire to prevent costs from rising too much as
a result of a higher carbon price, and that perhaps one of the
consequences of expanding the scale of the ETS might be to keep
the carbon price down. Could you clarify how you propose to resolve
this tension? There is no doubt that a higher carbon price does
encourage businesses to think about low-carbon investment but
it may also feed through into prices. How do you resolve that?
Mr O'Brien: It certainly will
feed through into prices. The whole aim of creating an ETS is
essentially to develop a market and that market will have a price.
That price will go up and it will go down. We have seen that it
was quite high at about 29 and it has dropped to about 10
and it dropped at one point to about 8. We have seen a bit
of variability in that market. That is not necessarily a bad thing,
in the sense that the aim here is to create a marketand
when we were in Phase I it went right down to zero for a period,
which I think was a bad thing. We want to ensure that we have
a mechanism that has a degree of variability in itbecause
that is what markets dobut also a level of certainty, because
in order to deliver, the market needs to be able to send signals
to those who are looking at various kinds of technologies that
those technologies will be commercially viable. We need to create
an effective market, where you have a reasonable level of certainty,
but in so far as you can create itand remember we are creating
something political herethat it moves towards, as soon
as we can, an effective commercial market where it is setting
a price and where there is a proper system of trading. To some
extent we are at the start of that process still, but we can do
that and create that market. There will always be a tension between
keeping the cost of this low and keeping the technologies in a
position where the carbon price encourages. That tension will
be there. In a sense, the market is there to help us move through
and seek to resolve that.
Q273 Chairman: Does it mean that
if you see the price consistently low you would be willing to
take action to try to force it up?
Mr O'Brien: Are you talking about
by creating some sort of floor in the carbon price?
Q274 Chairman: Or perhaps by reducing
the cap.
Mr O'Brien: Reducing the cap is
something that will obviously be looked at at Copenhagen and,
indeed, by the EU as part of that process. We have been consistently
trying to ensure that we reduce the cap in order to hit an emissions
target, but what you are now suggesting, it seems to me, if I
have this right, is that we manage the cap merely to manage the
carbon price. The primary objective here is to give some certainty
in reducing the level of emissions. The secondary objective is
to have this market and to ensure that we use that market to support
certain technologies. I think we need to keep in mind that we
need to look at it in that way. As far as creating some sort of
management, so that if it falls below a certain leveland
there is a question at what levelwe would then intervene
by reducing the cap in order to create a much more constrained
market or to use other kinds of mechanisms, I am concernedand
let me put this carefully. This is a market which has been created
by politicians, essentially, and we are trying to build it into
a market which effectively works commercially and achieves a political
outcome, an environmental outcome. We do not want to create a
market where the main bet is on what governments will do next.
The bet, the investment, should be in what is going to happen
in the long term in terms of this market. It should be a much
more commercial proposition rather than a bet at the next election
in Italy. We also need to be careful that we do not create a level
of dead weight in these mechanisms so that we, by creating a price,
by intervening politically, prevent a market from delivering what
it is supposed to do, which is essentially to reduce emissions
at the lowest cost. If you are intervening at a certain price
and you are saying, "This is it, it won't fall below this
level," there is the issue of whether we are then doing some
of these technologies at the lowest possible price. That is a
second concern I would have. A lot of political interference I
think would start to undermine some of the confidence in the market
and that would cause me some concerns. Also, at the moment prices
have gone down, but they have gone down for a reason. They have
gone down in the oil industry, they have gone down in a whole
load of other industries because we have a global recession. We
have a serious problem across the world in terms of the economythe
biggest problem we have had in decades. That will affect prices,
including the carbon price. Should we then start to intervene
and start to adjust it? We need to be very cautious about it,
but we can, I think, recognise that we are in the early stages
of creating a new market and our objective here is to have a market
that works. We need not to be so dogmatic about it and say we
would never intervene, but say that, in so far as we can, the
long-term objective here is to have a limited amount of political
interference. Copenhagen will be political interference, but that
we limit it in so far as it is as predictable as possible. Everyone
knows Copenhagen is going to happen, a deal could arise out of
it, that will affect things, that is predictable, but we do not
want it being adjusted constantly depending upon our national
preferencesand remember that may well be, say, in terms
of nuclear, national preferences for a particular technology.
Q275 Chairman: If we are trying to
create a market that is reasonably stable and operates in reasonably
predictable conditions, your memo has made it clear that you favour
expansion of the scope of the ETS, and we know that aviation is
clearly prime candidate for that, each time its scope is expanded
that introduces an element of uncertainty and, therefore, the
terms on which any new sectors are brought in are crucial. Do
you think it is possible to expand the scope in this way without
undermining the desirable degree of predictability and stability?
Mr O'Brien: Yes. I think it is
possible to do that. I do not want to sound Rumsfeldian, but there
are things that the market knows are going to happen, that it
can see. We have indicated that we want to bring aviation in and
that, therefore, will create a new area of trading. The market
can cope with that sort of change. I think it is more difficult
for the market to adjust to constant interventions, sometimes
at a national level, which will cause problems for the way in
which the EU ETS or a wider global ETS, if we get there or when
we get there, might operate. It is always a careful judgment but
can it manage new sectors? Yes, providing we give warning that
they are coming in and we say what we plan to do in terms of bringing
them in, I think that is entirely acceptable and does not create
a level of uncertainty for the market which the market cannot
manage. If we go beyond that, and we constantly, as somebody put
it to me, "mess about" with the way in which this market
operates from a political point of view, it may bring short-term
benefits but in the long term we undermine the way in which the
development of this market might occur.
Q276 Chairman: How will you judge
if Phase II has been a success?
Mr O'Brien: I think we have to
see whether we hit the emissions targets under Kyoto. My view,
as I have set out to you, is that the objective of the whole mechanism,
the whole system, is to see if we can reduce the level of emissions.
That over the long term is the test. But there are other tests
too with Phase II. That is the big picture test, but the others
are: Are we creating a market which is more sophisticated than
certainly it was under Phase I, which was really just a pilot.
Are we able to deal with some of the problems that have developednot
just in Phase I, which we sought to resolve to some extent in
Phase II and have had a fair degree of success in resolving. There
are still issues around CDMs; there are still issues around the
administration of the ETS; there is still a lot of refinement
to be carried on, the methodology, the accounting. I know everyone
thinks it is very slow and everyone wishes it could be done more
quickly, but we are creating a very large, very sophisticated,
very important mechanism, and we are having to refine it constantly.
Will we at the end of Phase II be in a position where we have
identified some more of the problems, resolved some more of the
problems, so that we go into Phase III with a clearer view? We
will in Phase III probably not have got it perfectly right, but
we will still be in the process of developing markets. As we all
know, markets tend to develop over a long period, but it will
constantly require the level of long-term political steer but
a commitment still to have a trading system rather than to have
a politically guided system.
Q277 Chairman: Do you have any concrete
evidence that emissions trading has so far produced a reduction
in emissions?
Mr O'Brien: There has been a lot
of criticism of Phase I, but if you look at the Massachusetts
Institute of Technology Report that suggested that Phase I had
produced a 4% reduction. Does it work? The solid evidence we have
up to now is thatand the MIT report seems to suggest that
there is some reason to believe that, yes, it works, and even
in a pilot scheme that was much criticisedquite rightlyit
seems to have produced some reduction. The NAO report which has
looked at this has said that 64% of the businesses which operate
in this scheme, about 900 installations in the UK, take into account
that there is an ETS system in terms of the decisions that they
make. We also have a market which is absolutely massive and trades
25 million tonnes a day. So there is a lot of work going on in
this market in itself, and therefore you are creating a commercial
opportunity, and that with a cap, and a cap that will progressively
tighten, aims to reduce emissions. I think there is quite a significant
amount of evidence to show that the system over the long term
will work. Up to now it has produced some results but we have
to work with it and try to refine it and make sure we have a system
that delivers in the long term.
Q278 Chairman: Would you agree that
because the severity of the recession understandably was not foreseen
at the time that the tighter caps for Phase II were being set,
unfortunately, it will be the recession that cuts emissions now
in Phase II and not the cap?
Mr O'Brien: It certainly is the
case that as a result of the level of activity in the economy
going down we will see the level of emissions going down. The
test is not so much whether the recession would have done it or
whether the ETS would have done it, but whether or not we had
a recession, would the ETS have done it. I think there are some
grounds for believing that the answer to that is yes. Also, because
companies, 64% of them in the NAO Report, are indicating that
the ETS is affecting their decision making and if it is the case
that they are making decisions based upon the ETS, then I think
we can say that, in any event, recession or not, the ETS is having
an effect by reducing emissions because companies are saying it
is having an effect upon the decisions that they are making and
because the market is building now. The prediction is that It
will be worth £97 billion in the course of this year.[1]
The EU ETS market was worth 63 billion in 2008, and the
global market was worth 86 billion. That is a big market.
That is bound to produce an impact. Therefore, I think we can
say that in any event the ETS is having an effect. Whether the
recession will have a bigger effect than the ETS, we will have
to wait and see. If that is the nub of the question you are asking,
I think we will just have to wait and see, but I think we can
say with some reasonable confidence that the ETS is having an
effect in any event.
Q279 Dr Turner: Government climate
change policy places a great deal of reliance on the EU ETS in
achieving a policy outcome of limiting temperature rise to no
more than 2°C. Given that background, one assumes that there
ought to be some numbers attached to this policy and to the ETS.
What levels of CO2 equivalent reductions does the Government feel
that the EU ETS needs to deliver within the EU to meet the 2°C
target?
Mr O'Brien: To some extent this
will depend on the outcomes at Copenhagen. As far as the UK is
concerned, we want to see a 16% reduction in our emissions in
sectors outside the EU ETS up to 2020, and if we have a deal,
a 30%, say, deal, across the EU as a result of Copenhagen, we
will be looking at 26%. That is overall outside the EU ETS. What
contribution ETS will make in addition to thatand remember
you cannot place all weight of climate change policy on the ETS
alone
Q280 Dr Turner: It would be foolish.
Mr O'Brien: It is a very important
part, but there is a range of other policies which we are pursuing
in any event. We have to look at the way in which we reduce emissions
as a whole, across the board. We are taking the view that we want
to see these reductions and we think the ETS will make a substantial
contribution to it, but the extent of it will be dependent upon
the way in which the ETS operates. The 16% is in non ETS areas,
but I think in terms of what we expect from the ETS itself, perhaps
David might set out some of the figures.
Mr Capper: The Phase II cap across
the whole of the EU is set at just over two billion tonnes of
CO2 equivalent. The cap that has been agreed in December as part
of the EU climate and energy package takes us down to about 1.7
billion tonnes by 2020. That in itself is a 300-400 million tonne
saving across the EU. If you compare it to the baseline figures,
the verified emission data for 2005, which are just over 2.2 billion
tonnes, then you see it is about a 500 million tonne saving. In
terms of the amount of emissions covered by the UK within the
EU ETS, this is difficult to calculate for 2020 because we have
a number of EU procedures and EU discussions that need to happen
before we get to the point where we will know exactly what numbers
of allowances we will be auctioning in Phase III and also the
numbers of allowances we will be giving free to installations
on UK territory. The estimates that the European Commission made
in their impact assessment on the EU 2020 package is that the
combination of those two things, the free allocation and the auctioning,
would lead to emissions of around 199 million tonnes in 2020,
which is below the current levels. We saw 265 million tonnes,
I believe, as the 2008 emissions from the UK installations. That
hopefully gives you some order of the magnitude, that really very,
very big savings happen in those sectors covered by EU ETS across
the whole of the EU. A saving that delivers something like 500
million tonnes over 15 years is really a pretty significant carbon
saving.
Q281 Dr Turner: Can we look at the
process of cap setting itself. Has that involved former scientific
modelling using numbers to arrive at a cap which will produce
the result we want, or has it in fact been a pragmatic process
of what can be politically achieved within the EU?
Mr O'Brien: I think it is part
of both. Perhaps David could go through some of the technical
stuff and then I will deal with the political side.
Mr Capper: The emissions trading
theory is that you set your overall target in relation to what
the science is telling you. This is why the EU has ended up with
this 20% unilateral target or the 30% target assuming a comprehensive
international agreement at Copenhagen. Under those targets, you
need to make a decision about which of those emissions will be
covered by the EU ETS and which of those emissions will be covered
by other policy instruments. The decision that the EU faced in
December last year was to determine the split of effort between
those sectors that are covered by EU ETS and those that are not
covered by EU ETS. The logical decision from an economic point
of view that the EU came to was that you would do it on the basis
of economic efficiency. The whole idea behind the EU ETS is that
you reduce emissions at least cost. It was agreed in December
that two-thirds of the effort to meet our 20% target will come
through the EU ETS cap, and so you have that process where you
have the overall targets which are determined by the science and
what is politically agreeable and then you have the process by
which you try go get those emission reductions at least cost.
Because of the efficiency of the EU ETS and the abatement potential
within the sectors covered by EU ETS, we have ended up with this
position where EU ETS sectors will reduce across the EU by 21%
compared to 2005 emissions by 2020.
Mr O'Brien: Chris will say something
on the science.
Mr Dodwell: Global emissions are
the key thing in terms of the 2°C target, because a tonne
of carbon emitted here is the same as a tonne of carbon emitted
anywhere else. The 30% target which the EU adopted was adopted
in line with the IPCC recommendation that we needed to have, in
Annex 1 terms, within the 25-40% range by 2020 and that other
developed countries also needed to take comparable effort to come
on board with those kinds of targets. Basically, this is aiming
towards a global peak in emissions by around 2020 and then decreasing
to very low levels, and at least half 1990 levels, by the middle
of the century. There are a number of ways you can draw these
trajectories. You can either frontload effort, which requires
obviously early political will, or you can delay effort, which
requires belief in the technical feasibility of rapid reductions
that can turn things round. We are doing some further work with
the Hadley Centre on trying to establish what these trajectories
really look like in global terms and then how you can relate that
to target the US is willing to take on but also the deviation
that you need from business as usual from developing countries
as well. The EU 30% is consistent with the IPCC's recommendation.
As David explained, the rest of the target for the EU ETS flows
down from those headline figures.
Mr O'Brien: In terms of politics,
obviously how much you are able to frontload depends on your domestic
politics. We and Italy may have different views on how much you
can afford to frontload and obviously the issue is still a very
moot one in the United States.
Q282 Dr Turner: We have heard some
interesting comments from David Kennedy, Chief Executive of the
Committee on Climate Change, that in Phase III of the EU ETS the
UK purchases of credits would mainly be paying power companies
in countries like Germany and Poland to switch from coal to gas.
In other words, our energy bills would be going up to pay German
power companies to do what they should be doing anyway, and in
no way would this be financing a step change in low-carbon technology.
Is this an intended outcome of the policy? I am sure it is not.
Mr O'Brien: It is not an intended
outcome. The overall aim is to reduce emissions and, clearly,
depending on carbon capture and storage issuesbut let us
leave those aside for a momentthe move from coal to gas
will contribute towards doing that, but the objective is to move
more effectively towards low-carbon generation rather than moving
simply to gaswhich of course has quite significant emissions
in any event.
Q283 Dr Turner: Does it not suggest
that there is a weakness in the cap-setting mechanism? If that
is what is happening in Germany and Poland, clearly the correct
incentive for Germany and Poland would have been to tighten the
cap on Germany and Poland rather than them being able to buy their
way out at our expense.
Mr O'Brien: We are part of EU
ETS. Some countries are taking a somewhat different view from
us in terms of how far they are prepared to move and how quickly
and how protective they want to be with some of their industries.
Whilst you are right in saying that from the UK's point of view,
as a country which is seeking to take a lead in encouraging the
process of reducing emissions, we would hope that other countries,
including countries like Poland, would have a view that they too
would want to see significant reductions, they, at the same time,
are also concerned that for all sorts of historical reasons they
want to continue to support the power generation that they have
for a bit longer. They are part of the system but they have problems
which they feel domestically they have to work through. In a sense,
it is precisely the point that I made earlier, which was that
for ourselves, for Italy, for Poland, the degree of frontloading
on all this depends on what the domestic politics will wear. Here
we have a broad consensus that we need to deal with this issue.
In some other countries there is a level of debate and also a
level of concern about the impact on their economywhich
is much greater than ours.
Q284 Dr Turner: How are all these
processes going to contribute to the development of low-carbon
technology development? What contribution do you think the EU
ETS process is going to make towards low-carbon technology development?
Mr O'Brien: It will ensure, as
the NAO Report says, that companies look when making decisions
at not just what the Government and the EU is suggesting they
should do but at what the emission trading system encourages them
to do and also at where the penalties would be if they do not
start to cut emissions. The more efficient companies will see
that there are benefits for them; the less efficient companies
will see that there are downsides, disadvantages for them, and
hopefully adjust their behaviour. In Phase III, when we are looking
at some of the benchmarking, we see that there is quite a lot
of encouragement there for companies in particular sectors to
match the best in their sectors. The average of the top 10% is
the benchmark. We are looking at trying to find ways in which
we encourage companies to do the best that they can in terms of
reducing emissions. Will it have an effect in the UK? Yes. In
fact, all the evidence is that it is already having an impact.
Dr Turner: We will come back to that.
Q285 Colin Challen: The attention
in Washington as to the Waxman-Markey Billwhich is being
reduced, it seems, in its ambitions as it goes through Congress:
I think it is now down to 17% CO2 cuts, 2020 target, but based
on a 2005 baseline, unlike our 1990 baselineeffectively,
as I understand it, it is equivalent to 4%. What implications
does that have for our 2020 targets in the EU, because we are
seeking to be a lot more ambitious than that?
Mr O'Brien: We are. I spent four
or five days in the United States the week before last talking
to some people from the administration and from Congress, and
also from some of the think tanks and the companies, about, among
other things, Waxman-Markey. It is clear that this has quite significant
implications. It is a major step for the United States from the
previous eight years. I think we need, first of all, to recognise
that. The debate in the United States is quite different, it seemed
to me, from the debate here. The debate there is primarily around
energy security rather than climate change. Climate change is
there, but as a secondary issue, whereas here climate change is
very much a leading issue and energy security is important too.
The debate in the US is different. We have seen quite a broad-based
bill and a very serious attempt by Waxman and Markey. They are
both seriously committed on these issues but they also operate
within a system where they know they have to do compromises. They
have tried a very broad-based bill. It has a number of controversial
areas in it, some of which will contribute towards dealing with
global warmingparticularly some of the issues around nuclear
are quite controversial, and they have tried to steer clear of
thembut we also know that when it gets into the Senate
the bill is going to have a lot more difficulty. We therefore
need to watch with care how this develops. If they are able to
set up a cap and trade system in the United States, that in itself
will be a major advance. That will be enormously important for
us and of great benefit for the EU ETS and of great benefit for
dealing with emissions on target. Will it be set up in the way
we would best like? Well, they are going to make their own decisions
rather than being told what to do by usthat is very clearbut
it is an ambitious bill within the American context. It is subject
still to a lot of debate. I suspect there will be some further
amendments to it. All the indications I got were that there was
a lot of controversy still around it. What are the implications
for us? I think the big one is really what are the Americans going
to do at Copenhagen. If they can get Waxman-Markey through this
year, that is the best window of opportunitybecause next
year is into the mid-terms, and this produces all sorts of political
issues for them, particularly in some of the coal states. The
question is: What is the administration's point of view going
to be? If they have got Waxman-Markey through by the end of the
year, or it looks like it is going to get through within a month
or two of the start of the following year, I think the administration
is in a stronger position. The administration's indications for
Copenhagen at the moment seem to be that they have learned some
of the lessons of Clinton on Kyoto (that is that Clinton wanted
Kyoto but Congress did not) and the impression I got from talking
to various people was that the administration had taken the view
that they wanted to ensure that whatever negotiating position
they had at Copenhagen was one which they could deliver through
Congress. They did not want to be back in the same position where
they just could not deliver this agreement. I think Waxman-Markey
will have quite an important impact for that on Europe and an
important impact too in terms of the way in which we are able
to negotiate and the deal we are able to negotiate at Copenhagen.
If we are able to get a cap and trade system at whatever level
that operates effectively in the US, that is a big step forward
and we must not underestimate the importance of it, even though
it may not be at the same sort of level that the EU has. One additional
point is of course if it is all set at a different level it makes
linking up the systems a bit more difficult, but I think in a
sense we have to work our way through that process over the coming
decades, developing this system by linking up various ETSs that
have been created is not of itself going to be an easy process.
Q286 Colin Challen: I would agree
with the statement that is taking a big step forward, particularly
on the record of the last eight years, but it does beg the question
of what benchmark we should put in placeand I assume that
we ought to put a benchmark in placein Copenhagen for our
intended budget of 30% by 2020. Effectively what the Americans
might be offeringand this is their best offeris
worse than Kyoto. Kyoto was 5% based on a 1990 baseline. If the
Americans are talking about 4% on a 1990 baseline, how is it we
can tell the public that we are going to increase our targets
by 2020 merely because the Americans are offering us that? That
surely is not the basis of a deal with Copenhagen.
Mr O'Brien: I think these things
are going to have to be negotiated. The American administration
will come to Copenhagen and we are hoping that they will come
with a view (a) to making a dealwhich is importantbut
(b) to doing it on a basis that will seriously drive down emissions.
At the moment there is a lot of contact going on, not just with
the United States and the EU but also with other countries, to
try to feel out what the negotiating positions are going to be
at the end of the year. The picture is still to some degree opaque.
The EU set out broadly where we want to go in January but the
US is still working its way through some of that process. If it
is the case that the US have a view about where they are going
to set their limits and that is very difficult for us, obviously
that is what negotiations are about and we will have to see how
that comes out. I mean, it is difficult to predict.
Q287 Colin Challen: I fully understand
the difficulties. This is perhaps the most intractable issue on
which to negotiate. A secondary point about Copenhagen, given
that we are talking of the 30% target if there is a deal, is what
constitutes a deal. People can sign an agreement, just as they
did in Kyoto, and then, as far as the States are concerned, they
have the same problem now as Clinton faced and that is getting
the treaty ratified.
Mr O'Brien: Yes.
Q288 Colin Challen: A big difficulty:
67 majority required in the Senate, I understand. Do we say, therefore,
that we would change the third phase of the ETS to a higher target
purely on the basis of people agreeing a deal, or is it based
on ratifying the deal? That is a key point as we have had all
the experience of Kyoto. What is the timing involved? The third
phase starts in 2012. Copenhagen or Kyoto plus whatever it is
should be ratified by 2012 to be continuous. What is the timing?
How do we start planning?
Mr O'Brien: At the moment we are
setting out where we want to be and what our proposals are. Once
we have got through Copenhagenand we all hope we will get
to a dealwe are then in a position where we will have to
make some judgments about what is going to be delivered and by
whom. It will not just be the United States that we are concerned
about, but the United States will be an absolute key player in
a successful outcome. We are going to watch very carefully what
is likely to be ratified by Congress. I have indicated where I
think the administration are looking at it. You are asking what
do we do and when do we announce things: Do we wait for the ratification
or not? I think we look at where we are when we have the deal
and we then make a judgment about where we go from there. We are
in a position where we are trying to set an ambitious agenda.
To some extent, some in America see it as much too ambitious.
We take the view that if we are going to hit some of the targets,
if we are going to have the reductions in emissions that we need
to have, then we need to be very ambitious indeed, but there is
still domestic politics in the US and other countries that we
have to take into account. I know that Chris wants to say something
about the US position.
Mr Dodwell: The Waxman numbers
that you have been citing refer to the 85% of the economy covered
by their cap and trade system and it is important to recognise
that they do envisage additional reductions being made on top
of that. First, through a significant portion of finance going
to finance reductions in international deforestation that could
add up to a further 10% on top of the numbers that you were mentioning.
This would take them to around 15% against 1990 levels, since
we are viewing this as a "target" rather than necessarily
where the reductions actually take place. Secondly, there are
complementary measures in the Bill standards and other policies
for the energy sector. Also, the Obama administration have just
announced a new initiative on vehicle standards. It may well be,
therefore, that there are additional measures that take America
further than the headline number that you have just been citing.
We are really looking for countries to come forward with initial
propositions and then the ability to move forward further, to
higher targets. We have just seen the Australians in the last
month or so come out with a revised target where they will say
they will move to 25% under the right sort of political conditions
at Copenhagen. The Japanese will be announcing a mid-term target
later this month. It looks like that, again, is going to be some
form of unilateral target which might suggest that it could go
further under appropriate conditions or by the use of financial
flows, offsets into other countries. Then, finally, just to come
back to the process in the EU, what is set out in the European
legislation is that the Commission will review the situation after
Copenhagen on the basis of what the agreement looks like and then
will come forward within three months with a proposal on how the
EU should move forward, including where the relative distribution
of effort should be between the traded and non-traded sector,
and that would be what would lead to the renegotiation of the
ETS Directive and the legislative measures covering the non-traded
sectors.
Mr O'Brien: When I was saying
"we" I was talking about the EU at that point. The UK
has a view about what the EU should do. The EU will then have
to work through its own negotiations with the Commission and agree
what it decides collectively to do.
Q289 Colin Challen: In terms of the
proposed increase of 30%, what is your view on how much of that
should be domestic effort within Europe or how much of it is going
to be, if you like, bought in from developing countries?
Mr O'Brien: This is very important.
The maximum amount of domestic effort should be made, but we also
have to recognise that the global phenomena of global warming
means that we want to encourage developing countries also to make
an effort. There is not a complete answer to your question because
we will need to see what the outcome of Copenhagen is for developing
countries and whether CDMs or something similar, sectoral deals,
or however we are going to go forward in developing countries.
Let us see where we come out at the end of Copenhagen, with the
mechanisms that are available for developing countries, and, therefore,
how much contribution the developed countries have to make and
what their role is, what the nature of those contributions is
and how they are going to be made, and whether we are keeping
CDMs and in what context, in what reformed way. There are a lot
of question marks around this, but as a basic proposition, a sort
of position of principle, we want to see the maximum effort made
domestically. We want to keep open the option of purchasing various
kinds of credits because they can have a significant effect in
other countriesand this is a global issuebut we
have been clear in saying that we want the maximum amount of effort
domestically.
Q290 Colin Challen: If that 30% does
not kick in and we stick with the 20%, what happens after 2020?
Because everything is going to have to be upped, the ambition
will have to go practically off the scale. The Kyoto experience
does not inspire a great deal of confidence that we can up our
efforts after a long period of endeavouring to get 5%, regardless
of our own UK position or that of Germany, which, for various
reasons, has hit he Kyoto target.
Mr O'Brien: I was listening yesterday
to Mr Tanaka from the International Energy Agency. He gave a lecture
at Chatham House. It was on the record, so I can talk about it.
He was emphasising the amount of expenditure that there needs
to be to make the emissions reductions, the change, the energy
revolution that we need, and comparing it to the stimulus packages
that have been announced in the last year. He claimed that we
are talking, over a longer period, of figures six times that amount,
just in terms of the level of investment, much of it coming from
the private sector, that you have to put into making the level
of change happen. I have not had a chance to look at Mr Tanaka's
figures, so they are not government figures, but you are right
to say that if the level of ambition post-Copenhagen is not as
high as we hope it will beand there is a great deal of
ambition on the part of the UK that Copenhagen should succeed
and deliver significant changes, but if, say, it does not work
out that wayby 2020, yes, we will be in a very difficult
position worldwide because the level of effort required to be
made will be enormous, and Mr Tanaka's figures may well be on
the low side by 2020. Who knows?
Q291 Chairman: Looking at the global
position, you have touched once or twice on the question about
how the EU Emissions Trading System might be linked up with the
wider system realistically? When do you think we could see a global
system which is robust enough to drive a carbon price which will
incentivise investment in low-carbon economies?
Mr O'Brien: I do not have a clear
date. Jill wants to say something on this.
Ms Duggan: We have a European
position on how we think that might be developedwhich is
probably optimistic and ambitious, but there is no harm in being
optimistic and ambitiouswhich is to have OECD countries,
have a series of linked trading systems by 2015 with major sectors
from advanced developing economies linked into that by 2020, looking
towards the development of a global carbon market at a company
level, company-based trading, by 2015, based on the assumptions
that developing countries reach a certain stage of development
before joining into that cap and trade, so that they get the benefits
of the Clean Development Mechanism or its successor prior to that.
We are looking at, over the next four decades, building up a carbon
market. Our experience in the UK and Europe is that we have learned
an awful lot over a relatively short space of time, but there
is still more to learn, and so certainly over the next decade
there will be a step-by-step process towards this.
Q292 Chairman: Are we arguing actively
with other countries to try to encourage them to move in this
direction?
Ms Duggan: We are certainly talking
to other Annex 1 and OECD countries about the benefits of linking
long-term, particularly linking company-based trading systems.
I think our experience would indicate, particularly our pilot
phase of the European Trading System, that it was useful for most
trading systems to run on their own for a couple of years to deal
with any unintended consequences. It is not an immediate goal;
it is a medium-term goal where other countries are open to those
arguments, but they do need to deal with domestic acceptance first.
Q293 Chairman: Are you encouraged
by the response that you are getting to these conversations?
Ms Duggan: I think we need to
recognise, as in the UK and Europe, that you need to get political
acceptance of cap and trade, which is something that they are
working very hard at in Australia, in the US and in Japan and
South Korea and other countries. The immediate goal is to get
acceptance for cap and trade and to get cap and trade running.
Once you have done that and you can deal with that within your
own domestic legislation, that is the time to start looking outwards
towards linking. Prior to that there is a need to be aware of
what you might need to design into your trading system in order
to make it linkable.
Q294 Chairman: Has any thought yet
been given to how we could link together schemes? Some will have
weaker caps, some will allow for a much greater use of offsets,
some might want to have price ceilings or price floors, but there
are a number of different characteristics which people could incorporate.
Certainly our discussions in Washington recently made me anxious
about the potential of offsets, for example, in the US cap and
trade system. Has work been done on how you can make all these
different schemes compatible?
Ms Duggan: There has been a certain
amount of work. The work that has been done to date indicates
that there are technical fixes for everything pretty much, but
of course it is the political certainty and the transparency,
as far as business is concerned, that is going to be important.
I think that will be a negotiation and probably a certain amount
of compromise between trading systems to do what we have learned
in Europe, which is that we have learned that we need to harmonise
to get that transparency over time and Phase I to Phase II to
Phase III has taken us in that direction. Other nations are not
yet in that position and I think you need to start trading quite
often in order to recognise the need for harmonisation.
Mr O'Brien: Australia and New
Zealand are in a position where they are looking to start in 2011.
The Japanese have their voluntary scheme. The South Koreans and
Taiwanese have expressed interest: they want to do something,
but what will they do? In a sense, we are in a situation where
we do not know what the other ETS schemes will be like. Much of
the work we can do now, in a sense, is to speculate and to try
to work out how we can deal it, but, as Jill says, the view is
that there are technical fixes to these things and that should
enable us to begin some element of linking up. The view generally
from talking to other countries is that they envisage a link upof
course, always on their own terms.
Q295 Mr Caton: Minister, in your
opening statement you foresaw us continuing to use cap and trade
even beyond 2050at least as a possibility. Lord Stern has
argued, however, that in the years towards 2050 the scope for
trading will get less and less as the opportunities for low-cost
abatement dry up and the countries have to do more at home. He
says, "We would expect the volume or trade to rise over the
next 20 years or so and then start to fall. That would be a feature
of success." In your opinion, when would emissions trading
effectively cease, with all countries having to concentrate on
decarbonising their own economy?
Mr O'Brien: I do not know the
answer to the question, in the sense that it all depends. I suppose
that is the only answer I can really give. But you are right that
Lord Stern took a view that the volume of trade would potentially,
in due course, start to reduce and countries would have to find
technological and other means. We see the ETS as an enormously
important mechanism to help us move towards less emissions but
we also know, all of us, that there will be a range of other ways
in which we do this. There is domestic government action in each
country. We have the energy efficiency and insulation projects
announced last September in this country and a range of other
things that we are doing. We know that other countries will also
develop their own schemes and technology, the introduction of
electric cars and the way in which we have a more sophisticated
grid, the so-called smart grid, where you can manage much more
effectively the amount of emissions that there are and the amount
of use of energy. There are a range of ways in which this market
will change over the years. Whilst I think Lord Stern is probably
right that the volume of pure carbon trading will reduce in the
long term, quite what the nature of the market will be in the
long term depends on a number of other technological as well as
other kinds of changes. It is, therefore, very difficult to predict
what exactly the ETS will look like, and we do not really know,
in 2040/2050, so I am sure, as sure as we can be looking into
crystal balls, that there will be a market mechanism ahead there
which will ensure that there is a commercial incentive in order
to reduce the level of emissions, that the amount of carbon emitted
hopefully will be substantially lower and, at that point, you
are in a position where the level of trade reduces, so it is difficult
to predict, but there will, I suspect, be some kind of trading
scheme into the future. The detail of how and what it will look
like, I bow to Lord Stern and his views.
Q296 Mr Caton: Returning to what
we were discussing a little earlier, the objective of creating
a world-wide carbon market, can I quote from the evidence that
we had from EDF,[2]
who said that the evolution of a global carbon market will take
too long "to meet the specific needs of the UK, where decisions
on the role of low-carbon technologies in replacing capacity over
the next ten to 15 years need to be taken now". By the time
the EU ETS has developed into a global carbon market, exactly
how relevant is it going to be to the kinds of actions that we
need to take to decarbonise the UK?
Mr O'Brien: Essentially, what
you are looking at is the way in which we have support available
for companies like EDF, for a carbon price and so on. They have
taken the view that they want to see some support for renewable
targets and for the development of nuclear as well through a carbon
price, and quite how, they are not entirely specific and I would
be interested to know precisely what they have said would be their
answer on this. They have various different views about what they
would want to create, so I would be interested in how they would
actually deliver on this.
Q297 Mr Caton: Do you share at all
their concern just about the timescale?
Mr O'Brien: Not to the extent
that they have put it, no. I think that what we do need to do
is make sure that we have other mechanisms which will ensure that
we deliver the reductions, and those have to happen in any event,
but I think you have to look at where EDF are coming from and
precisely what it is that they are looking for in terms of their
commercial position. They have been a very forward-looking company
in many ways, but they have also been a company that is operating
in a market.
Ms Duggan: I think you are right
in that it is very difficult to get a very high carbon price in
the short term that sends those very strong signals. I think what
we have learnt in Europe actually is that the continuation of
the market has been particularly important. The Minister has quoted
figures from the National Audit Office and also from the Point
Carbon Survey which found that participants, because they have
certainty on the continuance of the emissions trading system,
do take its future existence in account and the carbon price into
account in making investment decisions. However, we also have
other policies that are intended to help induce the right behaviour
in the short term, so in Europe we have a renewables target for
2020 as well as the emissions reduction target which sends that
very, very strong signal to EDF and other companies about the
direction of travel that is required. We have various funding
available through a variety of measures and a recognition that
there will be funding available, and David might want to say something
about the use of auction revenues across Europe post-2012 which
can help support some of those technologies which will be required
in the shorter term.
Mr O'Brien: I saw the comments
of Vincent de Rivas the other day in the newspaper, saying that
we needed to have more intervention to hold up the carbon price.
I know that that is his and EDF's view, that, in order to ensure
that the commercial propositions around nuclear are as good as
they want them to be, there should be that level of intervention.
I think, for the reasons I have already set out and I will not
repeat them, there are questions as to whether we should take
a political view and intervene and start supporting prices. We
have said that, as far as nuclear is concerned, we are not providing
subsidies for nuclear and that is our view. We think that nuclear
will actually wash its face itself and that is the view that EDF
have taken up to now, interestingly, as the carbon price has fallen
somewhat, as have other prices, due to the economic situation
globally, but EDF have taken the view that they would make the
statement that they have in the last few days. I think David wants
to say a few words on this.
Mr Capper: I was actually only
going to reflect on your previous question about what trading
will look like in the longer term because it is, I think, a surprisingly
poorly known fact that in terms of the EU ETS the world does not
stop in 2020. I think some people have the idea that what was
agreed in December is that we have set our cap to 2020, but we
have not said what happens beyond that, whereas actually what
was agreed in December does set the cap out in fact all the way
until it gets to zero, which is about 2066. Now, of course after
Copenhagen, assuming a successful agreement, we would hope that
you would have a tighter cap which would reduce even more quickly
than that, but I think that does give a good indication of where
in the longer term we would see trading going.
Q298 Colin Challen: Just following
on from this theme, I am a bit worried when we think too much
about the longer term and try perhaps to avoid getting our house
into order more immediately. The National Audit Office, in their
recent report, where I think the facts of that report were agreed
with DECC, concluded that the current price of EU ETS allowances
is "insufficient to stimulate major investment in low-carbon
technologies". Now, given that this report was agreed with
DECC, do you agree with that conclusion and what is being done
about it?
Mr O'Brien: Well, there are other
mechanisms in place to encourage low-carbon technologies, but,
in a sense, it comes back to Martin's point which was to what
extent and indeed Tim's point about the extent to which governments
should be intervening here, and I think we need to intervene in
particular ways to encourage, as we have done with the RO, the
development of certain kinds of renewables, and we have indicated
that we will support particular kinds of renewables and there
is, in a sense, a consumer subsidy which is in there to develop
those renewables, so we are not entirely reliant
Q299 Mr Caton: That is a recognition
of the failure of the ETS, is it not, in driving low-carbon technologies?
Mr O'Brien: No, far from it. It
is a recognition that you cannot put all the burden on ETS. ETS
is a mechanism, not the only mechanism, a very important mechanism,
but we have got to have a range of other mechanisms that will
enable us to deliver the amount of emissions that we need to make.
The idea that the ETS and the cap of itself can deliver everything
is just wrong. We are going to have to pursue in the coming decades,
and indeed now, a range of policies which enable us to reduce
emissions and to move to low-carbon technologies of different
kinds, and some of those are low-carbon technologies we have decided
that we will give subsidy support to through the consumer and
some of them we have not. I have got the signals from colleagues
who want to come in and add something to this.
Mr Capper: I think that this is
a widely accepted strategy for reducing emissions and I think
it goes back to, as somebody mentioned earlier, Lord Stern. The
Stern Report said very clearly that what you needed was to put
a price on carbon, which is what the EU ETS does, but that, in
order to reduce emissions, you do not just need to do that, you
also need to do other things, and one of the other things that
you need to do is develop specific mechanisms to bring forward
certain technologies that will be needed for a low-carbon future,
so, as the Minister said, what we are doing on renewables and
what we are doing on CCS are things which complement putting a
price on carbon. It is not a kind of either/or, but you need both
of these things in order to move to a low-carbon future.
Q300 Colin Challen: But an infamous
DTI leaked document a couple of years ago, widely reported in
the press, argued that we should not invest too much in low-carbon
technologies through direct public support because it would damage
the ETS. Those arguments are still quite live, I imagine.
Mr O'Brien: Well, I have not particularly
been party to any debate like that in recent months, certainly
since the setting up of DECC, but it is the case that, in anything
you do, you have to look at the implications for other policy
levers. What we are doing is developing an ETS which, we hope,
will be a significant policy lever that will have substantial
benefits for decades to come, but I would just repeat that it
is only one of a number of policy levers and we have got to pull
the whole range of them in order to get the sheer level. I think
there still is not out there broad public comprehension of the
degree of change that needs to be undertaken if we are to reach
the levels of reductions that we have to do. The sheer scale of
the level of investment is massive and it will require big investments
in nuclear, in renewables, in the grid, in wider connectivity
over a number of decades and at a high, sustained level of investment.
What we have with the ETS is a market mechanism which drives down
the level, we hope, or the aim of it is to drive down the level
of emissions and to create a market which will encourage the development
of those low-carbon technologies. Taken together, we can achieve
this green revolution. I often say to small groups of businessmen
in the energy industry who are sort of very perhaps conservative
in their outlook in all sorts of ways, basically the Che Guevaras
of the energy revolution, that the scale of what they are going
to do is going to be massive and they have got to grasp the sheer
scale of this and they and their companies are going to be making
these changes over a number of decades. This is a long-term thing,
and the ETS is one of the levers that we will use to deliver this,
but we will use a lot of other things as well.
Q301 Colin Challen: I agree that
we need a portfolio of things, including cap and trade, but is
it not true that the ETS has been the weak link in the chain up
to date, and perhaps it will get better, but perhaps one of the
ways it should get better is with a tighter cap which drives up
the price of carbon? Let us forget floors, let us just talk about
a tighter cap because is that not one way that we should address
this problem of its weakness?
Mr O'Brien: Well, a tighter cap
for ETS is certainly a mechanism that of course we are looking
at both at Copenhagen and beyond, so a tighter cap is part of
the mechanism, but putting everything on to that and saying that
that of itself will deliver everything is not going to be enough.
Has ETS been a weak link? Well, the weakest part of ETS so far,
and we are only at the start really, has been Phase I and, even
there, MIT suggest we had a 4% reduction. Now, if it had been
tighter and the cap had been tighter and we had not had all these
surplus allowances, maybe we could have delivered a lot more.
Well, of course, yes, in that sense, it was weak, but it was also
a success, so there is not a simple way in which we can either
dismiss it or say that ETS has been a great success. We are at
the start of developing a mechanism that will have to define itself,
get more sophisticated and change significantly over a longer
term so that it starts to deliver more effectively the things
which it is there for.
Mr Dodwell: A lot has been said
on the idea of trading schemes being effectively necessary, but
not sufficient, and I think that is clear. As David suggested,
we are over time wanting to send out a long-term signal that we
are moving to a zero-carbon energy economy and the cap effectively
does reduce to zero. That is what needs to happen over time and
to get to those parts of the mitigation cost curve that are more
expensive, you are going to need complementary measures, as we
are doing on CCS. But, in the meantime actually, with the abatement
techniques and the abatement that takes place, other things will
play a role, so the example you cited of moving from coal to gas,
that actually is a legitimate abatement technique. Were it not
for the establishment of a carbon price, coal would continue to
be burned in those plants in Germany and in Poland, and it is
a positive signal that people have seen that a carbon price is
effectively changing their behaviour and reducing global emissions.
The other thing I wanted just to comment on was actually the interdepartmental
working relationship which you sort of alluded to. Let us not
shy away from the fact that there is a potential tension between
different objectives, an objective of security of supply and an
objective of low-carbon technology, and the challenge that we
face and the challenge that DECC was put in place to address is
how to resolve those two things and take them forward in a way
which not just reflects both of those imperatives, but also in
a fair deal for consumers, for industry and business.
Q302 Colin Challen: The specific
point made in that leaked document was that, if you invest public
money and subsidise low-carbon technologies, that depresses the
price of carbon and, therefore, the ETS. That was the argument
that was used in that document and, I guess, that must still be
true.
Mr O'Brien: Well, it depends on
the cap, does it not?
Q303 Colin Challen: Well, yes, that
is why I came to the point about the cap.
Mr O'Brien: If you put in your
subsidies and encourage low-carbon technnologies, yes, I suppose,
if your cap stays at a certain level, that will depress the price
of carbon, but, if your cap reduces at the same time as you are
doing the subsidy, then you have still got the market, therefore,
and a price should be being set within that market.
Q304 Colin Challen: And that work
is being done presumably?
Mr Dodwell: But, equally, if you
are complementing an existing price in order to effectively encourage
the use of technologies that would not be picked up at that carbon
price, then they do not work against each other, they complement
each other.
Mr O'Brien: There is also a need
sometimes, as we are doing with CCS, to decide that the market
simply will not fund a particular change in technology and there
has got to be a political intervention in order to create a funding
stream for that.
Mr Dodwell: I did just want to
make one other point about the working relationship and the political
conditions in the UK. I think we have to recognise how much ahead
of the field we are in terms of the resolution of tensions between
different departmental priorities and in terms of the political
conditions in comparison with other countries. You see the debates
in Australia, you see the debates in Japan and the debates in
the US and you do not have the same coincidence of objectives
and of aims. You have industry effectively pushing back against
the low-carbon agenda because they are concerned or they are in
a state which, you will recall, we were perhaps in before the
introduction of the EU ETS. One of the things, I think, we do
have to consider, and I know the Committee is active in pursuing
this, is sharing our experience of actually how you can overcome
initial resistance from stakeholders so that they can begin to
see the prosperity agenda here, that there are actually opportunities
in this move to low-carbon technologies which allow you to address
both the climate change objectives and your energy security objectives
at the same time.
Q305 Joan Walley: Minister, I am
still perhaps concerned that there just appear to be mixed messages
coming out because, on the one hand, the evidence that you gave
to us says that the EU ETS provides "a long-term price signal
sought by investors" and just now you told us that obviously
that is not the only thing, it is part of a whole raft of measures
that is going to deal with this. When we had EDF sitting in those
same seats a couple of weeks or so ago, they told us that they
did not believe that the long-term signals would be there, at
the moment, beyond Phase III. The implication of what they were
saying is that, in the absence of any clear, long-term signals
for Phase III and beyond, that affected the decisions that they
were making about their investment now, and basically they were
saying that they would have to take decisions now about what to
invest in and that the payback time for them would be beyond 2017
and there is no clear indication about what the price of carbon
would be at that stage. They were saying that effectively it will
just lead to them building more gas-fired power stations, and
I just wonder how you are responding to those concerns.
Mr O'Brien: Well, in a sense,
they are right, but we do not want to build too much into that.
Forward markets develop over a period of time and at the moment
the carbon market, because it is linked so tightly to the energy
market, has not got a long-term forward market built up yet, so,
if you wanted to, say, work out what the price of forward purchase
in 2017 is on the carbon market, well, you cannot do that very
effectively because everyone knows that decisions are going to
be made post-Copenhagen, whatever they are, and that, one way
or another, is going to have an implication. In a sense, EDF are
stating partly the blindingly obvious, but also I think that,
if they are saying that means that, because we have not got a
clear carbon price set for 2017 yet, we, therefore, cannot make
a decision on whether to build a nuclear reactor, I think they
are going to move towards building a nuclear reactor in any event.
They have just invested £12.5 billion in buying British energy,
so the idea that they are not going to do anything at all is,
I think, probably unlikely. EDF are here because they want to
make long-term profits in the UK in the energy market here, they
see it as an enormously good market, we welcome them here, we
want to see them do well as well as other companies, but the decisions
that they make are not all going to be based on whether they can
predict what the carbon price is going to be in 2017 when their
first nuclear power station opens; I simply do not buy that.
Q306 Joan Walley: But is there not
as part of this whole debate a further issue, and you said just
now that there was going to be this level playing field and that
the Government was not going to be coming in and giving preferential
treatment to certain aspects of different investments, but is
it not the case that, unless the Government underwrites any or
some of the extra costs
Mr O'Brien: Sorry, underwrites
the extra costs of ETS or other technologies?
Q307 Joan Walley: Are the people
who are wanting to invest wanting to see exactly what these extra
measures are that the Government will be bringing in alongside
the price of carbon and the EU ETS?
Mr O'Brien: Of course, every company
that is making an advanced decision on investment on the scale
that a company like EDF is making, particularly in the nuclear
industry, would like to minimise the level of risk and have as
many variables as they can turn into certainties. That is just
a natural commercial wish, but it is also the case that companies
are in the business of making commercial decisions to manage risk
and there is always, always going to be a series of variables
which they are, therefore, going to have to deal with in terms
of making commercial decisions. Today it is the same as ten years
ago and it will be the same in ten years. What they have, however,
in this area is a clear government sense of direction, a broad
level of stability in terms of political consensus, far more than
exists in many other countries, which is why this country in many
ways is a desirable country to invest in, and a clear sense of
direction about where we are going and what we want to do and
the broad role that an ETS will have. They do not need to have
a carbon price fixed for 2017 in order to make a decision about
investing in a nuclear power station.
Q308 Joan Walley: But am I right
in thinking that EDF have urged you to introduce carbon contracts
that could underwrite the extra costs of low-carbon technologies
and, if that is the case, what has your response been because
it seems to me that that is more than just knowing what the long-term
direction of government policy is going to be?
Mr O'Brien: EDF would like to
have more government support for a number of its projects. I suspect
that, if we approached a number of other companies and we were
suggesting that we would offer all kinds of support, they would
say "Please".
Q309 Joan Walley: When you say "more
government support", would you just set out what that means?
Mr O'Brien: Well, I think they
would like any support they can get. They are making massive investments
and they want certainty, predictability and whatever grants, support
and incentives that they can get. That is natural, that is what
every company in this area will want, but, from our point of view,
what we have to do is ensure that we look after the interests
of the consumer, we ensure that we deliver on the objectives of
government policy in terms of climate change, that we do all of
this at an affordable price and that we preserve energy security
in the process, so we have got broad objectives too in terms of
climate change, security and affordability. Those we have very
much in mind and, when we talk to EDF, we look at what commercial
decisions we think they are likely to make and they will have
to make their own commercial decisions, and it is the same with
them as for all the other companies. They would like, no doubt,
to have the Government make life easier for them and, to some
extent, we work with them, but we always have to bear in mind
that the taxpayer/consumer are the people who put us here as a
government and it is their long-term interests that we have to
bear in mind in this, not necessarily how much profit a particular
company, whoever it is, is going to make or what demands they
make on the Exchequer to provide particular support for them.
Mr Dodwell: We have listened a
great deal to the views of energy companies and broader industrial
stakeholders in the position that we have taken on the carbon
market. When the review of the ETS came up, it was the UK that
put forward a lot of the proposals that are designed to give industry
long-term certainty. Certainty about the level of cap, in particular,
was our number one priority during the negotiations and it was
largely driven by a wish not only to get some environmental integrity
so that you could see a future pathway, but also so that you would
have that a predictable regulatory framework for business so that
they would know what the demands would be, so we are well aware
of those concerns. I think the issue actually that is forcing
concern at the moment is that businesses are discounting for the
risk of whether or not the EU will continue to go it alone if
no one else moves forward on the international sphere, and they
continue to see that as a risk that they cannot manage and, therefore,
they discount it in their internal business decision-making process.
As we have set out, there does seem to be a movement globally
towards carbon trading as being the instrument of choice; there
is a lot of interest in other developed countries and there is
a lot of interest in developing countries as well in taking this
forward, so we see a long-term future for that and the EU has
set out its long-term vision. That, to an extent, is us moving
and doing what we think is appropriate to respond to the concern
about long-term signals and long-term carbon pricing, and that
also underlies, in part, why we have taken such a positive and
active position in the international negotiations because we see
that we want to have a predictable international framework which
complements what we are doing in the EU and that then can provide
clarity and longer-term certainty to business globally about the
direction of travel and about what policy levers are going to
be in place in other countries as well as in our own.
Q310 Mr Caton: During this inquiry,
we have heard the argument that the ETS cap also acts as a floor
on emissions, so the point was made to us that, if we in the UK
cut our consumption of electricity, it will not cut emissions
overall, it will simply leave the power sector with more allowances
which, in turn, lower the carbon price and reduce pressure on
industry. Do you see that as a problem and, if so, how do we deal
with it?
Mr Capper: In essence, the point
you are suggesting is theoretically possible, but, if you have
other measures in place that reduce emissions and you keep your
cap level fixed, then of course there is less pressure within
the system in terms of what the carbon price will be, and the
carbon price may indeed be slightly lower. I think that this misses
really the big picture, and the big picture is that the more emissions
reductions you make, whether they are driven by the EU ETS or
whether they are driven by these complementary measures on technology
support, what it does is it allows you to move faster so that,
when we come to the political debates around what the EU ETS cap
should be post-Copenhagen, when we come to future debates about
what the level of the cap should be within Europe or indeed within
a linked global system, then, if you have already made the emissions
reductions, it is going to be much easier to get tighter caps
in the future and these measures then reinforce each other and
pave the way for that low-carbon future that we are looking to
deliver.
Q311 Mr Caton: The non-government
organisation that raised this with us, Sandbag, put forward a
means of going faster, as you say, and they suggest that the Government
ought to retain a reserve of ETS allowances which it would retire
in response to additional efforts to cut emissions from the traded
sector in the UK, thus actually lowering emissions below the initial
cap. Is that a runner?
Mr O'Brien: Sandbag have proposed
in fact a number of mechanisms, including people buying themselves
some of these allowances so that they can be, in effect, retired.
Obviously, if it were done on a governmental scale, individual
governments can reduce the amount of allowances circulating and,
therefore, effectively reduce the cap. I think this is an interesting
idea worth looking at, but what impact it would have on the market
as a whole, I think, needs to be worked through, so I would not
dismiss it as a concept. What I am wary about again is whether
we are in the business of creating a political market or a commercial
market and, if we are in a situation where the market price is
going to be manipulated by the Government by this means of retiring
various credits or allowances or indeed various other mechanisms,
then the risk is that some who are involved in the market will
say that that produces a level of uncertainty, so there would
have to be some way of ensuring that the policy was clear as to
how it would all be used if that were done, so I think it is an
idea worth looking at. Their idea of individuals doing it, unless
they were particularly wealthy individuals, is probably at the
margin and that is why they are now looking at governments doing
it, and I treat it with caution, but it is an idea worth looking
at.
Q312 Chairman: It is generally agreed
that in Phase I too many allowances were allocated.
Mr O'Brien: Yes.
Q313 Chairman: During Phase I Britain
purchased quite a lot of allowances. Does that raise the question
of whether the effect of those did not actually achieve any emissions
reductions at all?
Mr O'Brien: Well, the objective
was to produce a reduction in emissions. There are two questions:
was there a reduction in emissions in the UK; and was there a
reduction in emissions worldwide? There was an overall reduction
in emissions, MIT's report suggests that that was the case, and
it is the case that we took the view that we would want to see
that reduction in emissions being effective. Now, did we do as
much as we could in the UK? Well, we took the view that there
was a significant reduction, it was not as massive as if we had
not purchased the credits, for example, but overall there was
a reduction.
Q314 Chairman: But there is a flaw,
is there not, in a system which allows offsets to be purchased
from countries which do not themselves have a target?
Mr O'Brien: It depends what you
mean by a "flaw". Yes, we would like other countries
to have targets and, yes, we would like them, at least in developing
countries, to have sectoral targets and sectoral policies, but
is it not right to encourage other countries to take steps which
will reduce the level of emissions? Yes, I think it is right.
It certainly was envisaged in Kyoto. The ETS rules allow provision
of various offsets, whether offsets through CDMs outside the EU
or various kinds of EU allowances and internal offsets, so our
view is that we are dealing with a global phenomenon and, therefore,
we need to recognise that. At the same time, we want to reduce
domestically our emissions, but we also want to find ways in which
we can encourage others to do so too. If, say, we denied access
to the various allowances, credits, offsets, however you want
to describe them, the UK companies would be disadvantaged, developing
countries might not get the investment that they need in order
to move towards a low-carbon economy, the reductions would occur
perhaps more cheaply and, remember, an ETS is about delivering
a reduction at the cheapest cost, so it could occur more cheaply,
but it probably would not happen and, therefore, I think you have
to have effective monitoring of these various offsets and we need
to look at this whole area at Copenhagen, but you must not use
the purchase of offsets as an excuse for doing nothing domestically.
Q315 Chairman: Well, let us look
ahead. Next year, your projections say that we will be a net purchaser
of 24 million EU ETS allowances in 2010, and that is how we are
going to achieve a reduction in our emissions. How many of those,
do you think, will be bought as offset credits from outside the
EU?
Mr Capper: It is the $64 million
question. How can you possibly know what companies' investment
strategies will be over the next year? We simply do not know that
information. What we do know is that in 2008 across the whole
of the EU around 4% of all the allowances or credits that will
be retired against the 2008 cap came from certified emissions
reduction units or emissions reduction units from either the Clean
Development Mechanism or Joint Implementation, so we know what
the situation was in 2008. You would say in 2009 that maybe a
similar level might be possible, but individual companies will
take individual decisions and that will reflect in what the final
outcome is.
Q316 Chairman: So you do not mind
what the proportion is?
Mr Capper: I think, in terms of
the EU as a whole, what we agreed in December is that we took
a kind of in-principle view that at least 50% of the reductions
should come from within the EU, so they should be domestic reductions
within the EU and that the remaining up to 50% could come from
the purchase of CERs or ERUs under the Clean Development Mechanism
and joint implementation. I think that you have got to recognise
that this is actually quite a big step forward in people's understanding
of needing to get this balance right between domestic abatement
and abatement that has perhaps been achieved overseas. If we just
looked at what happened in Phase II of the EU ETS, one of the
problems with Phase II of the EU ETS is that actually, by Member
States all taking individual decisions on their national allocation
plans within the EU ETS and those being approved by the European
Commission, what we found was that, if you added up all the abatement
offsets allowed by purchase from overseas, it came to 226% of
the emissions reductions required in the system, so what we decided
in December, collectively as the EU, is that we would change this
226%, which was far too high in terms of how many emissions could
be bought from overseas, and we would reduce that over the period
2008 to 2020 to be at least 50% of the reductions occurring in
the EU, so that is quite a significant shift in terms of the EU
saying, "Actually, we need to have quite a lot of this abatement
happening domestically over this period up to 2020".
Mr Dodwell: As David has said,
we are leading the debate again in Europe on the source of demand,
but we are obviously interested in the supply as well as being
interested in the quality of the offsets that are purchased, and
we are addressing this on two fronts. Firstly, in terms of reform
of the current CDM, we are very active in the negotiations and
indeed our representative is a UK representative on the CDM Executive
Board whose work is primarily aimed at improving the efficiency
and the transparency of the assessment process, but at the same
time we want to improve the effectiveness of the instrument, and
we have been championing the use of sectoral benchmarks that allow
you to effectively achieve additional reductions through still
a project-based mechanism, but also in developing special approaches
for some particular sectors where abatement will not be particularly
cheap, and you will be aware of the HFC question, and that is
something which we are actively pursuing in the negotiations.
Also, we are advocating a move away from project-based systems,
which effectively give credit against business as usual, to sectoral
approaches, which have advantages both for environmental integrity,
but also for financial flows for developing countries. You can
cluster together individual projects, you start to look at them
first programmatically, but then at a sectoral level and then
you start to see some major increases in financial flows to those
countries, but also, because you have set a benchmark that is
considerably lower than business as usual, you are delivering
much more in terms of emissions reductions. So we do recognise
that the CDM itself needs to change as well as controlling, as
David said, the demand for those credits.
Mr O'Brien: The Stern Review of
course took the view that these ought to be permitted, but monitored
and looked at very carefully and should not be an excuse for failing
to act domestically, and of course, from the Government's point
of view, we are introducing carbon budgets across government and
we have taken the view that the purchase of credits in the first
place would not be something that we wanted to see.
Q317 Chairman: Well, I welcome the
recognition that the answers you have given reflect. One of the
proposals in the US Waxman-Markey Bill has recognised that offsets
are not really worth the same as cuts made within the cap, and
it suggests that there will be a differential value and you would
have to surrender five credits to cover four tonnes of emissions.
Is that kind of approach one which you would like to see introduced
into the EU ETS?
Ms Duggan: I think actually that
the amendment to the ETS directive, which takes account of 2020
to 2030,[3]
does allow the EU to make those decisions about whether to discount
certain allowances, and that is dependent on the outcome of the
negotiations in Copenhagen, so, if, for example, CDM continued
to allow allowances which, we felt, should not be recognised at
full face value, then we would be able to discount them. I think
that is what the Waxman-Markey Bill is still doing, particularly
for international credits; it is allowing that ability, but it
is not, depending on how its passage goes, necessarily going to
continue through, and I think the domestic credits have already
lost that discounting in the Waxman-Markey Bill.
Q318 Chairman: But, as a principle,
do you think that this is helpful?
Ms Duggan: It is useful leverage
perhaps to ensure the quality of credits that come through and,
therefore, it is certainly useful to have the ability to discount
them even if you do not actually have to use it.
Q319 Colin Challen: The Government
has agreed with the European Council in its non-legally binding
declaration that auction proceeds or half of those proceeds should
be spent on tackling climate change either at home or in developing
countries. I am just wondering how that is, or will, work through
in UK policy terms.
Mr O'Brien: Well, we certainly
accept that half, and probably more than that, are going to end
up going into various kinds of projects to encourage a low-carbon
economy, but the question really is: should we be hypothecating
all the ETS auction revenue? Our view is that no, we are not going
to directly hypothecate on a significant scale, but the EU rules,
you are right, do say that at least half of the revenue should
go on climate change issues. Also, additionally, there is the
300 EUAs, the allowances, which are helping to finance the 12
CCS projects and other technologies, something which we argued
for, so that is quite significant. The Government also, over a
number of years, but even in the Budget this year, has made clear
that we want to put a lot of funding into projects. We are not
sort of directly hypothecating it, but we are putting the money
in in any event. We will not go through the normal Treasury arguments
around hypothecation, but the question really is: is money going
in in any event? There was the £405 million for the low-carbon
technologies, the £335 million for the energy efficiency
schemes and insulation schemes for homes and businesses, £45
million for micro-generation and other smaller schemes, £25
million for the community heating scheme and so on, so, even in
the Budget this year, there was a recognition of the importance
of ensuring that there was very substantial funding going in to
helping the low-carbon technologies, dealing with issues around
insulation and energy efficiency and delivering on the wider project
of creating a low-carbon economy.
Q320 Colin Challen: Well, President
Obama's original proposal for cap and trade, and they talk about
100% auctioned, was to produce a tax rebate so that American taxpayers
would get something back from those auction proceeds. Is that
not a rather attractive idea? Have we looked at it and considered
it? I am sure it might win a few votes for the incumbent Government.
If people got their carbon cheques every year, would that not
actually engage them in this whole debate in a way which at the
moment the majority of people are not engaged?
Mr O'Brien: Well, I listened with
care to the advocates when the legislation was going through Parliament
of feed-in tariffs and renewable heat incentives and the sorts
of changes which we do think are needed to create incentives for
people to develop low-carbon alternatives and technologies. We
do provide particular subsidies for micro-generation now and we
tend to do it in more than a slightly different way from the Americans,
but, in our case, it is reasonably effectively targeted and what
we will see, I hope, from April next year, when we introduce feed-in
tariffs, is that we are providing a mechanism to encourage communities
to develop their own technologies and in the longer term, in terms
of the renewable heat incentive, I hope we will be able to do
that the following year. There are different ways in which you
can do these things. Traditionally, the Americans have done it
simply by giving tax credits and we have tended to do it by a
combination of means, the key one of which is by giving direct
grants for particular outcomes; much more measurable, much more
targeted. I think there are arguments for both, but we have taken
the view that doing these things directly would be a preferable
way because we know what we are getting for a certain expenditure
of money. There have been various concessions from time to time
of a smaller nature than the sort that Obama is now proposing
in relation to various kinds of technologies and the development
of them, particularly in terms of small companies getting tax
benefits, tax credits, so there is an argument for this, but,
given that there is always limited financing here, what is the
best way of delivering the outcome, and we have taken the view
that the ways we have chosen heretofore are the best ways.
Q321 Collin Challen: The first two
auctions have taken place. Have we learnt any specific lessons
from the way that those have been handled and what has occurred?
Mr O'Brien: Well, I think the
auctions have actually gone very well. We had the first one on
19 November 2008 when four million allowances were sold. The price
turned out then at £13.60, and the result that we got back
was £54 million and it was four times over-subscribed, and
I think the final point about the over-subscribed nature of them
was an education and interesting. The one on 24 March this year
sold a similar amount of allowances. The price came down to £10.12
on average and it was six times over-subscribed nonetheless as,
remember, this is 24 March, well into the economic difficulties
that we have had. On Thursday, we have got the third. We do not
know what the price will be obviously, we will have to wait and
see, but the amount will be much greater over the next year with
27 million allowances in eight auctions. I think we have learnt
a number of things so far. We have set up the six primary participants
who are investment banks and they are being encouraged to bring
in various companies and installations who will seek to purchase
the allowances, and it seems to have worked reasonably well. I
think we are still discovering what the best way is of doing this.
The Treasury have taken the view that there needed to be a greater
incentive on the primary participants to encourage others to join
the process of bidding, so there is now an incentive fee paid
to the six to encourage them to bring in more bidders, but I think
we have been encouraged by how well it has gone so far. It bodes
well, I think, for the long term, but, before I start saying that
it has all been a wonderful success, let us get Thursday out of
the way.
Q322 Collin Challen: So you would
not want to hazard a guess as to how much might be raised in future
auctions, particularly going into Phase III, an estimate?
Mr O'Brien: Well, it depends on
the price, so it would be simply a guess and I think it would
be probably unwise to do so; let us see how this process goes.
So far, I think you could say that we are extremely encouraged.
Q323 Dr Turner: The European Commission
has got a proposal that, "for advanced developing countries
and highly competitive economic sectors, the project-based CDM
should be phased out in favour of moving to a sectoral carbon
market crediting mechanism". Do you know exactly what is
meant by that, and do you think that it deals with the problems
we all know about with improving additionality and verification
of the existing CDMs?
Mr O'Brien: The key problem with
CDMs has been just making sure that they deliver what they are
supposed to deliver, and I was very struck by the article in,
I think it was, The Mail on Sunday over the weekend which
looked at the way in which some of these markets are operating.
We need to ensure that we can bring out some reforms of the CDMs,
but I know that Chris wanted to say a word on this.
Mr Dodwell: There are two things
here, and one particularly relates to the point which was made
about market shocks and the ability to expand the market, that
this development needs to take place in a phased way where there
is clarity about the amount of emissions that you are talking
about and there are monitoring and reporting arrangements put
in place before any kinds of benchmarks or targets are set by
those sectors which effectively result in caps, so this is a progression
over time. We would like to see these sorts of arrangements in
place by 2020 with parties effectively having the option of taking
them up in intermediate stages. The other is that these reforms
need to be seen in the context of broader action by developing
countries more generally and the European position on this, and
indeed the UK position on this, is that developing countries need
to be developing their own low-carbon development strategies,
which can signal within them a broad level of ambition, decarbonisation,
some sort of target that sets a level of ambition for the plans.
Countries can then put forward proposals to the international
community for sectoral trading, say, or for other policies for
which they are seeking international support. Therefore, there
is a complementary relationship whereby carbon finance and carbon
markets can provide credits where you can set a credible sectoral
benchmark or a sectoral baseline for a cap, but also where you
have other policies which are being encouraged or incentivised
by other public finance. So it is very much complementary to the
overall position on climate finance. One of the things that we
have been trying to do in terms of the international debate here
is to say that the governance model needs to be looked at in terms
of delivery of finance to developing countries to encourage low-carbon
approaches, and the UNFCCC and the other arrangements which are
currently in place were not designed to handle the levels of financial
flows that we are talking about here. In terms of how actual markets
might work, how a sectoral crediting system might work, we have
got some experience of that in the UK. We have done a similar
approach for the climate change agreements where they operated
on a sectoral credit baseline and credit approach whereby, at
the end of a period, you would effectively receive a sector-received
credit if it beat the negotiated benchmark. A trading approach
actually is very similar to a cap and trade approach that you
have in the EU in that you receive the allowances upfront, so
there are advantages from the perspective of the companies that
are regulated in that they receive the allowances upfront and
they can start to consider how to behave with those allowances,
so this is an evolution away from project-by-project-based approaches
whereby you move to something which is more sectoral, as I was
mentioning earlier, where the benchmarks can reflect some real
effort. There are a number of different models that are under
development as to how the detail of the systems would work.
Q324 Dr Turner: So do you think that
this could be of any value? For instance, if, let us say, India
and China do not want to sign up to a global regime with a binding
cap, do you think they would be more prepared to sign up their
major industries to sectoral schemes?
Mr Dodwell: Well, that is our
objective. The Chinese have begun to make announcements which
suggest that they are open to this idea and they have been talking
about, in their next five-year plan, extending that perhaps for
a ten-year time horizon and having a carbon intensity target for
the whole of the Chinese economy. They have also indicated that
they are interested in discussing, as have other developing countries
like South Africa, how these sorts of sectoral approaches might
work. What we need to do here is to build incentives into the
system so that you are not reliant on harsh compliance penalties
which, as we know, do not operate particularly effectively at
the international level and, instead, there is an incentive for
participation and an incentive for countries to take more ambitious
action.
Mr O'Brien: What the countries
like India, China, South Africa and so on are looking for is more
funding to come from Western countries in order to fund all of
this, and that means that there is an ability to encourage the
development of a sectoral approach in their countries by us, providing
that it is done in a way which actually delivers change. Now,
the difficulty of course is that the funding mechanism for that,
CDMs, at the moment we have got concerns about the administration,
the transparency, the methodology behind it and how the CDM Executive
has been undertaking its responsibilities. We sought some reforms
at Poznan and did not get very far with that. There are clearly
quite worrying aspects of it around HFCs in China and the way
in which the Chinese have now decided to tax the money going into
China because there is so much money going in, so there is clearly
a need for significant reform of the CDMs. A sectoral approach
could give us the ability to carry out some of those reforms,
but it will not be easy to put in place and, I suspect, we are
not talking about this happening in the next year, but this will
take some time to negotiate, to put in place and also to work
out what sort of funding streams from Western countries would
deliver the results that we want to see.
Q325 Colin Challen: The DECC memo
to this Committee[4]
says that the CDM "helps to drive global investment in low-carbon
technologies" and supports developing countries in moving
away from high-emitting `business as usual' developments. What
proportion of CDM investments are actually going to low- or zero-carbon
technologies as opposed to something which is merely just more
efficient, like coal plants that are being built today?
Mr O'Brien: Certainly, much of
it is going into more efficient rather than very low or zero.
As we know, there is probably no zero.
Mr Dodwell: I do not have figures
on the sectoral split, but we can do what we can to provide the
material.[5]
I think it is quite difficult to get a complete, holistic view
and, in particular, your categorisation of sort of mainstream
technologies rather than transformational technologies. It was
partly with this in mind that last year we set up the Climate
Investment Fund with other G8 countries and other countries contributing
to them because we recognised that, just as in the UK you can
have a carbon price that kind of exists and which changes behaviours,
but does not necessarily get to the transformational technologies
that you need, so that happens with the CDM and, indeed, even
if you have a broader carbon price. That is why we set up the
Clean Technologies Fund which now has had a number of bids which
have come in, been reviewed and some of them in fact just been
approved, I think country investment plans where you have effectively
got a country like Mexico coming forward with a real transformational
plan as to specific initiatives where it needs funding from the
international community to put in place. I believe that the Mexican
plan is something in the order of $500 million. Now, the CDM last
year was worth $6.5 billion, so that is the amount of money that
is actually going into developing countries, and that was down
a little on the previous year, so these two things need to operate
in a complementary way. Just as we were saying with UK policy
you need to have both things that encourage the efficient use,
the sort of smaller changes, you also need support for the big,
transformational changes.
Q326 Colin Challen: So our position,
the Government's position, on using the CDM is to support maybe
more efficient fossil fuel-based technologies, do we not really
take a view on that, or do we rather tend not to support it because
we have this other mechanism?
Mr O'Brien: Well, if we can encourage
the development of CCS or if we can develop the technologies which
are going to ensure that developing countries are able to both
develop an increasing rate, but also do so without increased emissions,
then that is something that we are not unhappy about, but I think
there is a real risk here that, if we try to be overly prescriptive,
we could reduce the opportunities for people to become involved
in this kind of investment. The price of doing that may well be
significant because we could, at a reasonably low cost, reduce
the amount of emissions from some developing countries. This is
probably, of all the issues across the area of the ETS, the most
difficult one because we know that this is a global problem, we
know that it does not matter where the reduction happens and,
in a sense, we just need the reduction to happen and it needs
to be permanent. You can probably do it more cheaply in developing
countries, but we also need to know that we are the main polluters
and we need to make sure that we are the ones that set the lead
and make the cuts here. In terms of how we help developing countries,
we want to help them to develop low-carbon technologies, but that
does not mean zero-carbon technologies, it means lower and low,
both.
Q327 Chairman: Thank you very much.
We have covered a bit of ground this morning and we are very grateful
to you and your officials for coming in, and I am sure we shall
reflect a lot of what you have said in our Report.
Mr O'Brien: Thank you, and can
I just say thank you to my officials for the briefing I have had
from them.
1 Note by Witness: The EU ETS market was worth
63 billion in 2008, and the global market was worth 86
billion. Back
2
Ev 80 Back
3
Note by Witness: The witness meant to refer to the ETS
directive, taking account of 20-30% by 2020. Back
4
Ev 127 Back
5
Note: See Ev 144 Back
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